The FCC Used a Blunt Rule to Shut Chinese Robots Out of the Door
The FCC put mobile robots on the covered list, barring all new models from import. The reason isn't technological superiority — it's that supply-chain dependence gets harder to fix the longer you wait, so a crude rule beats a finely tailored exemption.
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The argument · tap a timestamp to hear it
The covered list is not a sanctions list, and the FCC can't change it alone
The FCC's covered list is not the same as the OFAC sanctions list or the BIS entity list: the FCC has no authority to update the list itself. Another national security agency or an interagency body must first make a determination, and only then can the FCC update and enforce it. Devices on the list cannot get import or marketing authorization. The FCC doesn't just regulate spectrum and broadcasting — nearly every electronic device that emits radio frequency must pass FCC certification before it can be imported, marketed or sold. That little FCC logo is the tool, and it's also the switch that can cut off new models at the border.
— Adam ChanRobots are the only bet that hasn't taken shape yet
Adam sorted the FCC's recent covered list actions into categories: undersea cables, telecom and drones all have clear industries and demonstrated impact, while mobile robots are still a very early industry. His read is that there is good reason to see this action as staking out a position five years ahead. The driver is the lesson from telecom networks in 2019 and 2020 — at the time U.S. domestic telecom networks depended almost entirely on Huawei and ZTE equipment, forcing a large-scale rip-and-replace. The U.S. government's thinking now is: don't let the same thing happen again in a critical industry like robotics.
— Adam ChanA crude rule runs faster than a finely tailored one
Facing the charge that this is too blunt, Adam's response is that simple, even dumb, rules are often the best rules. It avoids two things — naming specific entities, and the whack-a-mole problem that comes from writing complex definitions with long transition periods; at the same time it sends a strong signal to the market, drawing in capital and investment. He also concedes the tool will hit unintended targets, but argues it can be patched afterward: the drone definition was initially very broad, and a later determination exempted toy drones; the robot determination likewise builds in a conditional approval process that lets companies apply for exemptions.
— Adam ChanThe real risk isn't being unable to buy — it's being unable to build at all
The host raises a sharp counter-question: the choice may not be ‘Chinese robots vs. American robots’ but ‘Chinese robots vs. an American robot ecosystem that doesn't exist at all.’ Adam's answer has two layers: first, the cheapest and easiest moment to fix supply-chain dependence is now, and the longer you wait the more commercial incentives lock the dependence in; second, the covered list generally only affects new models, which amounts to a transition period of a few years, not a sudden cutoff. His evidence: after the drone action there has already been more than five billion dollars of investment, over a million square feet of manufacturing capacity and thousands of jobs; in routers, where there were originally zero domestic U.S. manufacturers, dozens of companies have now committed to expanding production.
— Adam ChanResearch use and teardown practice both get a carve-out
The rule builds in several categories of exceptions: imports and sales for U.S. government use are unaffected; small-batch imports for product development can also continue. Adam mentions a specific scenario — some U.S. counter-drone companies import foreign drones precisely to practice shooting them down, and as long as they meet other FCC rules and stay under the quantity cap, that is still allowed. He also notes an exemption on the drone side: any drone or component on the Defense Department's blue UAS list is cleared, and many of those are actually made overseas or in allied countries, such as Ukraine.
— Adam ChanTo get an exemption, you first have to hand in an onshoring plan
The conditional approval process requires companies to submit an onshoring plan explaining how they intend to move production back to the United States. Adam says the enforcement branch does not intend to hand companies a blank exemption to ‘keep producing overseas,’ even if the company has no obvious risk from an ownership or cybersecurity standpoint. He also gives a quantitative threshold: if it meets the definition of a ‘U.S. domestic end product’ — assembled in the United States, with 65% of components by value made in the U.S. — that is enough, which also means a portion of components can still be imported.
— Adam ChanYou don't need to believe in AGI to support this rule
The host asks: how much would you have to believe in AGI to think this rule matters? Adam's answer is that most people should be uncertain about AGI anyway — humanoid robots could turn out to be a complete dud after 2027, or they could genuinely be critical, and the rule means entirely different things in those two cases. But he points out it holds up without the AGI narrative: mobile robots in warehouses and quadruped robot dogs for public safety don't need the kind of AI model we dream about to already play an important role in the economy, and mobile robots sourced from foreign suppliers pose a risk just the same.
— Adam ChanEnforcement is already moving: a company lied about U.S. manufacturing
Adam says the FCC will stay busy on both the rulemaking and enforcement tracks. He cites a case currently under investigation: a company claimed on its application form that it manufactured in the United States when it did not, and the manufacturer listed on the form confirmed it had never heard of the company. The FCC is also dealing with drone companies that won't cooperate with investigations, and with behavior that may circumvent covered list restrictions through rebranding. The FCC also has a program called bad labs, aimed at the labs that do device testing for the FCC.
— Adam ChanIn their own words · checked verbatim
I think there's actually a strong argument in this case and other examples of sort of FCC policy of the sort of simple and stupid policy actually being the best policy whereby it allows for fast action.
Adam Chan10:40
the least expensive and easiest time to address a supply chain dependency is right now. It's only going to get harder as these industries grow and as all the sort of basic commercial incentives are to continue to entrench the dependency.
Adam Chan18:56
We've seen something like routers. Actually, there were zero entities that produce routers in America. But as of now, there are dozens of companies that have committed to actually expanding production of routers in this country.
Adam Chan20:00
you don't need to be, have the sort of AI models that we can only dream of to, you know, have those play sort of significant role in the economy.
Adam Chan32:44
if Unitree wants to set up a factory in the United States and produce robots, nothing is, nothing is stopping them under the FCC action.
Adam Chan33:51
all the national security rules, um, and, you know, enforcement action, penalty, fine type things that we've brought have all been bipartisan, unanimous.
Adam Chan44:13
Figures
| Total FCC employees | about 1,200 | 43:12 |
| FCC budget | about $400 million | 43:12 |
| Investment attracted after the drone action | more than $5 billion | 15:50 |
| Component threshold in the U.S. domestic end product definition | 65% made in the U.S. by value | 26:22 |
| China's share of components such as magnets in the robot ecosystem | 99% | 17:52 |
| Public comment period for the drone rule | 30 days | 41:08 |
Glossary
- covered list
- A list of equipment and services the FCC established under two laws in 2020 and 2021; devices on it cannot get import or marketing authorization.
- conditional approval
- A process by which companies can apply for an exemption; they must submit an onshoring plan, and review is led by the Defense Department.
- blue UAS list
- The U.S. Defense Department's list of drones approved for sale to the military; those on it are exempt from FCC restrictions.
- bad labs
- An FCC program targeting the labs that perform device testing for the commission.
- onshoring plan
- A plan that must be submitted with a conditional approval application, explaining how production will be moved back to the United States.
How to listen
Founders and investors watching U.S.-China tech decoupling, hardware supply chains and the robotics sector; policy researchers who want to understand how the U.S. export-control toolbox actually operates.
The chit-chat after 44:13 about FCC work culture, hiring and law school advice can be skipped.